Dear Aleksey and all, We would like to clarify the situation because the policy refers to transfers between RIPE NCC members and not transfers between the LIR accounts that members might hold. A member may hold multiple LIR accounts. Regarding the section that you refer to in the procedure, please see the mail that was sent to the NCC Announce mailing list in October: https://www.ripe.net/ripe/mail/archives/ncc-announce/2018-October/001286.htm... This message explains how the RIPE NCC processes transfers of IPv4 address space or 16-bit ASNs due to a merger, acquisition or any other change in business structure. We hope this clarifies that no policy violation has taken place. A merger or acquisition is possible at any time and must take place following the processes outlined in the email. Kind regards, Marco Schmidt Policy Officer RIPE NCC